TOTAL CALCULATIONS OF OFFSETS

Norfolk Southern Train Calculations Norfolk Southern Trains Before and After Amount Train 1BSFC 2 Activity Factor

20 Tier 0/unregulated 14.83 52000 10 GP33CO- ECO "mother" 17.19 45727 10 Empty "slug" 0 0 Input data 1 Average of BSFC (brake specific fuel consumption) listed in the attached Norfolk Southern contract (page 39, among others) Input data 2 Activity factor (gal/yr) assumed in Norfolk Southern Contract (page 39, among others) Input data 3 Emission factor (EPA in its “Technical Highlights” document titled: “Emission Factors for Locomotives”. The link to this information is located at: http://www.epa.gov/nonroad/locomotv/420f09025.pdf) Input data 4See middle chart of attached Norfolk Southern Contract for BSFC, Activity and Emission Factors for GP33CO ECO trains (the clean replacements) Calc. Step 1 Ten trains are converted to "slugs" which power no engine so the initial emission (10.71 tons/train-in a year) is equivalent to emissions savings (10.71 tons-0 tons=10.71) per train. So 10.71 x 10 =107.1 Calc. Step 2 Ten trains are converted to "mothers" which power the cleaner GP33CO ECO trains so the emissions benefit is initial emission (10.71 tons/train-in a year) minus final emission (6.07 tons/train in a year) for a savings of about 4.64 tons per "mother" (10.71 tons-6.07 tons=4.64) per train. So 4.64 x 10 = 46.4 Calc. Step 3 Sum these trains together and total savings is about 153.56 tons (107.10 tons + 46.46 tons if we conserve significant figures to two digits past the decimal)

Norfolk Southern Calculation Rationale While there have been estimates made in the past regarding emission benefits (see contract), there is uncertainty regarding the exact trains to be replaced and how these trains exactly were used in the rail yards in Atlanta. The most appropriate conservative estimate for our purposes is to the use the rates for switchers of Tier 0, 12.6 g/bhp-hr as provided by EPA in its “Technical Highlights” document titled: “Emission Factors for Locomotives”. The link to this information is located at: http://www.epa.gov/nonroad/locomotv/420f09025.pdf The 12.6 g/bhp-hr estimate is conservative since the locomotives actually are a mix of uncontrolled and Tier 0 with the relevant emission factor limit for Tier 0 (overhauled before 2010 and after 2000) actually 14.0 g/bhp-hr according to 73 FR 88 25098-25352 (2008) and 63 FR 18997-19084 (1998). The use of EPA estimates for emission factors are further supported by the assumption of EPA default duty cycles. In addition, since not sure about the exact activity of trains in the Atlanta Yard to be replaced, the average of BSFC values provided in the NS contract (14.83 bhp-hr/gal) was used and 52000 gal/yr fuel consumption assumption was applied. Keep in mind, again, that this is fulfilled with CONSERVATIVE assumptions. One could reasonably have not only assumed 14.0 g/bhp-hr instead of 12.6 g/bhp-hr for these old Tier 0 locomotives, but also taken into account in the calculations that many of the original trains were uncontrolled (up to 17.4 g/bhp-hr, see "Emission Factors for Locomotives", link: http://www.epa.gov/nonroad/locomotv/420f09025.pdf). The 12.6 g/bhp-hr emission factor is within the range of emission factors claimed in the Norfolk Southern contract (8.3-12.82 g/bhp-hr, a "range of uncertainty"), further supporting the validity of this assumption. CSX CalculationsCSX followed similar methodology as GA EPD applied for Norfolk Southern (assumed 12.4 g/bhp-hr emission factor fleet average, very similar to EPD as it referenced this as a conservative estimate instead of using 14.0 g/bhp), and reported 5.9 tons/locomotive per year. With 6 trains, it comes to 5.9 x 6 = 35.4 tons total. We went with this estimate. See attached CSX contract (specifically look at pages 20-21, except 6 trains, not 5) and emissions estimate of 5.9 tons saved per year per train replacement.Tons/year Sig Figs

10 Norfolk Southern "slugs" 107.1073265 10 Norfolk Southern "mothers" 46.45453893 Total Norfolk Southern 153.5618654 CSX: 6 train replacements 35.4 Subtotal 188.9618654 Rome 8.42 Diesel Bus Program 6.42 Total Offset 203.8018654 203.8 Total Offset Required 202.35 202.35 Offset>Offset Required since total offset available is 203.8 tons and total offset needed for GA Marketing Rule Removal is 202.35 tons so a successful demonstration.

3Emission Factor 4Conversion (g to ton) Tons Emission per train in a year 12.60 1.10231E-06 10.71073 7.00 1.10231E-06 6.065279 0 N/A 0 Average of BSFC (brake specific fuel consumption) listed in the attached Norfolk Southern contract (page 39, among others) Activity factor (gal/yr) assumed in Norfolk Southern Contract (page 39, among others) Emission factor (EPA in its “Technical Highlights” document titled: “Emission Factors for Locomotives”. The link to this information is located at: http://www.epa.gov/nonroad/locomotv/420f09025.pdf) See middle chart of attached Norfolk Southern Contract for BSFC, Activity and Emission Factors for GP33CO ECO trains (the clean replacements) Ten trains are converted to "slugs" which power no engine so the initial emission (10.71 tons/train-in a year) is equivalent to emissions savings (10.71 tons-0 tons=10.71) per train. So 10.71 x 10 =107.1 Ten trains are converted to "mothers" which power the cleaner GP33CO ECO trains so the emissions benefit is initial emission (10.71 tons/train-in a year) minus final emission (6.07 tons/train in a year) for a savings of about 4.64 tons per "mother" (10.71 tons-6.07 tons=4.64) per train. So 4.64 x 10 = 46.4 Sum these trains together and total savings is about 153.56 tons (107.10 tons + 46.46 tons if we conserve significant figures to two digits past the decimal)

While there have been estimates made in the past regarding emission benefits (see contract), there is uncertainty regarding the exact trains to be replaced and how these trains exactly were used in the rail yards in Atlanta. The most appropriate conservative estimate for our purposes is to the use the rates for switchers of Tier 0, 12.6 g/bhp-hr as provided by EPA in its “Technical Highlights” document titled: “Emission Factors for Locomotives”. The link to this information is located at: http://www.epa.gov/nonroad/locomotv/420f09025.pdf The 12.6 g/bhp-hr estimate is conservative since the locomotives actually are a mix of uncontrolled and Tier 0 with the relevant emission factor limit for Tier 0 (overhauled before 2010 and after 2000) actually 14.0 g/bhp-hr according to 73 FR 88 25098-25352 (2008) and 63 FR 18997-19084 (1998). The use of EPA estimates for emission factors are further supported by the assumption of EPA default duty cycles. In addition, since not sure about the exact activity of trains in the Atlanta Yard to be replaced, the average of BSFC values provided in the NS contract (14.83 bhp-hr/gal) was used and 52000 gal/yr fuel consumption assumption was applied. Keep in mind, again, that this is fulfilled with CONSERVATIVE assumptions. One could reasonably have not only assumed 14.0 g/bhp-hr instead of 12.6 g/bhp-hr for these old Tier 0 locomotives, but also taken into account in the calculations that many of the original trains were uncontrolled (up to 17.4 g/bhp-hr, see "Emission Factors for Locomotives", link: http://www.epa.gov/nonroad/locomotv/420f09025.pdf). The 12.6 g/bhp-hr emission factor is within the range of emission factors claimed in the Norfolk Southern contract (8.3-12.82 g/bhp-hr, a "range of uncertainty"), further supporting the validity of this assumption.CSX followed similar methodology as GA EPD applied for Norfolk Southern (assumed 12.4 g/bhp-hr emission factor fleet average, very similar to EPD as it referenced this as a conservative estimate instead of using 14.0 g/bhp), and reported 5.9 tons/locomotive per year. With 6 trains, it comes to 5.9 x 6 = 35.4 tons total. We went with this estimate. See attached CSX contract (specifically look at pages 20-21, except 6 trains, not 5) and emissions estimate of 5.9 tons saved per year per train replacement.Offset>Offset Required since total offset available is 203.8 tons and total offset needed for GA Marketing Rule Removal is 202.35 tons so a successful demonstration.

Emission factor (EPA in its “Technical Highlights” document titled: “Emission Factors for Locomotives”. The link to this information is located at: http://www.epa.gov/nonroad/locomotv/420f09025.pdf)
Ten trains are converted to "slugs" which power no engine so the initial emission (10.71 tons/train-in a year) is equivalent to emissions savings (10.71 tons-0 tons=10.71) per train. So 10.71 x 10 =107.1 Ten trains are converted to "mothers" which power the cleaner GP33CO ECO trains so the emissions benefit is initial emission (10.71 tons/train-in a year) minus final emission (6.07 tons/train in a year) for a savings of about 4.64 tons per "mother" (10.71 tons-6.07 tons=4.64) per train. So 4.64 x 10 = 46.4

While there have been estimates made in the past regarding emission benefits (see contract), there is uncertainty regarding the exact trains to be replaced and how these trains exactly were used in the rail yards in Atlanta. The most appropriate conservative estimate for our purposes is to the use the rates for switchers of Tier 0, 12.6 g/bhp-hr as provided by EPA in its “Technical Highlights” document titled: “Emission Factors for Locomotives”. The link to this information is located at: http://www.epa.gov/nonroad/locomotv/420f09025.pdf The 12.6 g/bhp-hr estimate is conservative since the locomotives actually are a mix of uncontrolled and Tier 0 with the relevant emission factor limit for Tier 0 (overhauled before 2010 and after 2000) actually 14.0 g/bhp-hr according to 73 FR 88 25098-25352 (2008) and 63 FR 18997-19084 (1998). The use of EPA estimates for emission factors are further supported by the assumption of EPA default duty cycles. In addition, since not sure about the exact activity of trains in the Atlanta Yard to be replaced, the average of BSFC values provided in the NS contract (14.83 bhp-hr/gal) was used and 52000 gal/yr fuel consumption assumption was applied. Keep in mind, again, that this is fulfilled with CONSERVATIVE assumptions. One could reasonably have not only assumed 14.0 g/bhp-hr instead of 12.6 g/bhp-hr for these old Tier 0 locomotives, but also taken into account in the calculations that many of the original trains were uncontrolled (up to 17.4 g/bhp-hr, see "Emission Factors for Locomotives", link: http://www.epa.gov/nonroad/locomotv/420f09025.pdf). The 12.6 g/bhp-hr emission factor is within the range of emission factors claimed in the Norfolk Southern contract (8.3-12.82 g/bhp-hr, a "range of uncertainty"), further supporting the validity of this assumption.CSX followed similar methodology as GA EPD applied for Norfolk Southern (assumed 12.4 g/bhp-hr emission factor fleet average, very similar to EPD as it referenced this as a conservative estimate instead of using 14.0 g/bhp), and reported 5.9 tons/locomotive per year. With 6 trains, it comes to 5.9 x 6 = 35.4 tons total. We went with this estimate.Ten trains are converted to "mothers" which power the cleaner GP33CO ECO trains so the emissions benefit is initial emission (10.71 tons/train-in a year) minus final emission (6.07 tons/train in a year) for a savings of about 4.64 tons per "mother" (10.71 tons-6.07 tons=4.64) per train. So 4.64 x 10 = 46.4

While there have been estimates made in the past regarding emission benefits (see contract), there is uncertainty regarding the exact trains to be replaced and how these trains exactly were used in the rail yards in Atlanta. The most appropriate conservative estimate for our purposes is to the use the rates for switchers of Tier 0, 12.6 g/bhp-hr as provided by EPA in its “Technical Highlights” document titled: “Emission Factors for Locomotives”. The link to this information is located at: http://www.epa.gov/nonroad/locomotv/420f09025.pdf The 12.6 g/bhp-hr estimate is conservative since the locomotives actually are a mix of uncontrolled and Tier 0 with the relevant emission factor limit for Tier 0 (overhauled before 2010 and after 2000) actually 14.0 g/bhp-hr according to 73 FR 88 25098-25352 (2008) and 63 FR 18997-19084 (1998). The use of EPA estimates for emission factors are further supported by the assumption of EPA default duty cycles. In addition, since not sure about the exact activity of trains in the Atlanta Yard to be replaced, the average of BSFC values provided in the NS contract (14.83 bhp-hr/gal) was used and 52000 gal/yr fuel consumption assumption was applied. Keep in mind, again, that this is fulfilled with CONSERVATIVE assumptions. One could reasonably have not only assumed 14.0 g/bhp-hr instead of 12.6 g/bhp-hr for these old Tier 0 locomotives, but also taken into account in the calculations that many of the original trains were uncontrolled (up to 17.4 g/bhp-hr, see "Emission Factors for Locomotives", link: http://www.epa.gov/nonroad/locomotv/420f09025.pdf). The 12.6 g/bhp-hr emission factor is within the range of emission factors claimed in the Norfolk Southern contract (8.3-12.82 g/bhp-hr, a "range of uncertainty"), further supporting the validity of this assumption.CSX followed similar methodology as GA EPD applied for Norfolk Southern (assumed 12.4 g/bhp-hr emission factor fleet average, very similar to EPD as it referenced this as a conservative estimate instead of using 14.0 g/bhp), and reported 5.9 tons/locomotive per year. With 6 trains, it comes to 5.9 x 6 = 35.4 tons total. We went with this estimate.While there have been estimates made in the past regarding emission benefits (see contract), there is uncertainty regarding the exact trains to be replaced and how these trains exactly were used in the rail yards in Atlanta. The most appropriate conservative estimate for our purposes is to the use the rates for switchers of Tier 0, 12.6 g/bhp-hr as provided by EPA in its “Technical Highlights” document titled: “Emission Factors for Locomotives”. The link to this information is located at: http://www.epa.gov/nonroad/locomotv/420f09025.pdf The 12.6 g/bhp-hr estimate is conservative since the locomotives actually are a mix of uncontrolled and Tier 0 with the relevant emission factor limit for Tier 0 (overhauled before 2010 and after 2000) actually 14.0 g/bhp-hr according to 73 FR 88 25098-25352 (2008) and 63 FR 18997-19084 (1998). The use of EPA estimates for emission factors are further supported by the assumption of EPA default duty cycles. In addition, since not sure about the exact activity of trains in the Atlanta Yard to be replaced, the average of BSFC values provided in the NS contract (14.83 bhp-hr/gal) was used and 52000 gal/yr fuel consumption assumption was applied. Keep in mind, again, that this is fulfilled with CONSERVATIVE assumptions. One could reasonably have not only assumed 14.0 g/bhp-hr instead of 12.6 g/bhp-hr for these old Tier 0 locomotives, but also taken into account in the calculations that many of the original trains were uncontrolled (up to 17.4 g/bhp-hr, see "Emission Factors for Locomotives", link: http://www.epa.gov/nonroad/locomotv/420f09025.pdf). The 12.6 g/bhp-hr emission factor is within the range of emission factors claimed in the Norfolk Southern contract (8.3-12.82 g/bhp-hr, a "range of uncertainty"), further supporting the validity of this assumption.While there have been estimates made in the past regarding emission benefits (see contract), there is uncertainty regarding the exact trains to be replaced and how these trains exactly were used in the rail yards in Atlanta. The most appropriate conservative estimate for our purposes is to the use the rates for switchers of Tier 0, 12.6 g/bhp-hr as provided by EPA in its “Technical Highlights” document titled: “Emission Factors for Locomotives”. The link to this information is located at: http://www.epa.gov/nonroad/locomotv/420f09025.pdf The 12.6 g/bhp-hr estimate is conservative since the locomotives actually are a mix of uncontrolled and Tier 0 with the relevant emission factor limit for Tier 0 (overhauled before 2010 and after 2000) actually 14.0 g/bhp-hr according to 73 FR 88 25098-25352 (2008) and 63 FR 18997-19084 (1998). The use of EPA estimates for emission factors are further supported by the assumption of EPA default duty cycles. In addition, since not sure about the exact activity of trains in the Atlanta Yard to be replaced, the average of BSFC values provided in the NS contract (14.83 bhp-hr/gal) was used and 52000 gal/yr fuel consumption assumption was applied. Keep in mind, again, that this is fulfilled with CONSERVATIVE assumptions. One could reasonably have not only assumed 14.0 g/bhp-hr instead of 12.6 g/bhp-hr for these old Tier 0 locomotives, but also taken into account in the calculations that many of the original trains were uncontrolled (up to 17.4 g/bhp-hr, see "Emission Factors for Locomotives", link: http://www.epa.gov/nonroad/locomotv/420f09025.pdf). The 12.6 g/bhp-hr emission factor is within the range of emission factors claimed in the Norfolk Southern contract (8.3-12.82 g/bhp-hr, a "range of uncertainty"), further supporting the validity of this assumption.The 12.6 g/bhp-hr estimate is conservative since the locomotives actually are a mix of uncontrolled and Tier 0 with the relevant emission factor limit for Tier 0 (overhauled before 2010 and after 2000) actually 14.0 g/bhp-hr according to 73 FR 88 25098-25352 (2008) and 63 FR 18997-19084 (1998). The use of EPA estimates for emission factors are further supported by the assumption of EPA default duty cycles. In addition, since not sure about the exact activity of trains in the Atlanta Yard to be replaced, the average of BSFC values provided in the NS contract (14.83 bhp-hr/gal) was used and 52000 gal/yr fuel consumption assumption was applied. Keep in mind, again, that this is fulfilled with CONSERVATIVE assumptions. One could reasonably have not only assumed 14.0 g/bhp-hr instead of 12.6 g/bhp-hr for these old Tier 0 locomotives, but also taken into account in the calculations that many of the original trains were uncontrolled (up to 17.4 g/bhp-hr, see "Emission Factors for Locomotives", link: http://www.epa.gov/nonroad/locomotv/420f09025.pdf). The 12.6 g/bhp-hr emission factor is within the range of emission factors claimed in the Norfolk Southern contract (8.3-12.82 g/bhp-hr, a "range of uncertainty"), further supporting the validity of this assumption.